- 15 - having an original depreciable basis of $4,000." We do not believe this provision is clear and unambiguous because it could be read on its own to limit the type of cattle held by the partnerships. However, we interpret this paragraph as qualifying the one directly proceeding it which limits the number of cattle subject to depreciation for each year, and neither party has suggested a different interpretation. After considering these provisions and the agreement as a whole, we reject petitioner's argument that the provision limiting the number of depreciable cattle should be read to limit the total number of cattle held by the partnerships. Even if we found the agreement ambiguous as to this provision, petitioner has offered no extrinsic evidence that supports petitioner's position. We find that the agreement limits only the number of cattle subject to depreciation, but does not limit the number of nondepreciable cattle owned by the partnerships. Petitioner further argues that the portion of the agreement which provides that principal payments will begin in the sixth year of the partnership should be enforced by including that such payments are to be made by the transfer of registered shorthorn heifers. The language of the agreement is silent as to the method of payment. Petitioner's proffered evidence, when considered in light ofPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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